Joris Reijnierse

Pillar Two update - The Belgian tax authorities published today a message that they will provide an administrative tolerance until 16 September for the notification form for Pillar Two for entities that will not carry out advance payments in 2024 for (Belgian) domestic top-up tax or IIR. For groups that wish to carry out advance payments in 2024, the deadline remains 13 July. https://lnkd.in/eYPP54DE #Deloitte #PillarTwo

29

The Belgian #Tax Authorities have opened a public consultation on the draft (Q)DMTT-return, with a deadline of 8 November 2024. With the first (Q)DMTT filing deadline set for 30 November 2025 (for fiscal years ending on 31 December 2024), businesses face a limited window to prepare. This public consultation aims to gather insights that will help finalize the return template and XSD-schema. Don’t forget, Belgium's minimum taxation law also introduces a prepayment system for the (Q)DMTT and the IIR Top-up Tax. Make sure your organization is ready—timely preparation is key! Find out more: https://bit.ly/3UjyAXT #Belgium #KPMGBelgium #KPMGTax

4

I had the pleasure to discuss the latest #Pillar2 developments in Belgium together with my coleague Pieter Deré. The pillar 2 advance payment system for any DMTT or IIR tax liability in Belgium is now live. There are however some important attention points. Thanks Stephanie Soong from Tax Notes for working together on this article! #pwc #pwcbelgium #tax #internationaltax

58

2 Comments

[#LetsTalkGlobalTax] Under the Dutch CIT rules, profits and capital gains related to participations are exempt for tax purposes. This also limits the deductibility of costs that directly relate to the acquisition or sale of such a participation. Thierry Boonstra, M&A Director, and Marco Hulsman, M&A Tax Advisor, Mazars in Nederland, provide a breakdown of this legal principle: http://maza.rs/6042Y8Ymg

2

📢 Deadline Belgian Pillar Two Notification Form extended till 𝟭𝟲 𝗦𝗲𝗽𝘁𝗲𝗺𝗯𝗲𝗿 𝟮𝟬𝟮𝟰 ! 🛑 Note: This administrative tolerance for the extended deadline applies only to groups that will not make Belgian advance payments for the 2024 QDMTT and/or IIR. For those planning to make advance payments for the Belgian QDMTT and IIR in 2024, the original deadline remains in effect. 💼 𝗡𝗲𝗲𝗱 𝗔𝘀𝘀𝗶𝘀𝘁𝗮𝗻𝗰𝗲? If you have questions or require support with the Belgian Pillar Two Notification Form, please reach out to the EY contact person on this alert. #PillarTwo #QDMTT #FPSFinance

11

Earlier today Belgium announced an extension of the deadline to file the Pillar Two notification to 16 September. Importantly, the extension is available to MNE Groups that are not required to make estimated payments for Belgium global minimum tax. The extension is welcome news for many companies that do not expect to incur top-up tax in Belgium. #eytax #beps #pillartwo

39

The Belgian #Tax Authorities have opened a public consultation on the draft (Q)DMTT-return, with a deadline of 8 November 2024. With the first (Q)DMTT filing deadline set for 30 November 2025 (for fiscal years ending on 31 December 2024), businesses face a limited window to prepare. This public consultation aims to gather insights that will help finalize the return template and XSD-schema. Don’t forget, Belgium's minimum taxation law also introduces a prepayment system for the (Q)DMTT and the IIR Top-up Tax. Make sure your organization is ready—timely preparation is key! Find out more: https://bit.ly/3UjyAXT #Belgium #KPMGBelgium #KPMGTax

6

On 🗓️ 21 June 2024, the Economic and Financial Affairs Council (#ECOFIN), under the Belgian presidency, faced another setback as the 27 EU member states failed to reach an agreement on the VAT in the Digital Age (#ViDA) proposal. Despite this, all member states commended the Belgian presidency for its hard work to reach a consensus 💪🏻. The baton will now be passed to Hungary, which will assume the EU Council presidency as of July. A key takeaway is the consensus among member states on the DRR pillar! The only veto came from Estonia, concerning the new deemed supplier regime, which imposes VAT collection responsibilities on platforms facilitating short-term accommodation rentals and passenger transport. Read the full alert below ⬇️ #VIDA #Einvoicing #Ereporting #DRR #ECOFIN #Deloitte

10

A project we have been working on for the last two years or so: the establishment of our Mazars Financial Services Transfer Pricing Center of Excellence. Check out our website in the link and experience the value added services and solutions that this can bring to your organization #mazars #financialservices #banking #capitalmarkets #insurance #transferpricing #tax #london

64

📣 Belgium further expands its transfer pricing documentation and filing requirements 📣 📅 On 15 July 2024, Belgium has issued new Royal Decrees, updating the transfer pricing documentation requirements for qualifying taxpayers. 📝 The new Royal Decrees, introduce additional information requirements for both the Local and Master File Forms. They mandate the submission of transfer pricing documentation, framework agreements, or model contracts. For country-by-country notifications, the submission of Form 275.CBC.NOT is now required also in case of termination of the notification obligation. 📊 The new model for the forms will apply to financial years starting on 1 January 2025. Know more by reading our latest Transfer Pricing alert! https://lnkd.in/eF8PsXTA #EY #EYBelgium #BelgiumTax #Tax #TransferPricing #BEPS #OECD #TaxCompliance

8

Apparently #pillar2 filing requirements coming to life. In-scope taxpayers to file P2 notification Form with specific data to obtain a pillar two tax identification number. This will help them with future advance tax payments and filings. #beps #internationaltax #belgium

8

Last year, Belgium officially implemented the Pillar 2 rules, which introduce a minimum tax for companies like yours. To ensure compliance, all affected groups must register at the Crossroads Bank for Enterprises (Kruispuntbank van Ondernemingen / Banque Carrefour des Entreprises). Stay tuned, as the detailed guidelines outlined in a Royal Decree dated 15 May 2024 will soon be published in the Belgian Official Gazette (Belgisch Staatsblad / Moniteur Belge). In the meantime, you can find the preliminary information on the Pillar 2 section of the Belgian tax authorities' here: https://bit.ly/3WQtLY8

1

Important upcoming BEPS filing requirment. Multinationals subject to Pillar Two, having either a Belgian ultimate parent entity, or one (or more) Belgian constituent entity(ies), are required to file a Pillar Two Notification in Belgium by 13 July 2024 (or 30 days following the start of the financial reporting year for the MNE group if this is later). The volume of information required to be disclosed in the P2 Notification Form is substantial (requires entity P2 qualification understanding) and is detailed in the attached alerts.

11

What are the main challenges faced by companies trying to implement a more sustainable business model? A recent survey by BDO Belgium and Mercuri Urval shows those and how to overcome them:

1

📣 EY Tax alert: 𝗕𝗲𝗹𝗴𝗶𝘂𝗺 𝗵𝗼𝗹𝗱𝘀 𝗽𝘂𝗯𝗹𝗶𝗰 𝗰𝗼𝗻𝘀𝘂𝗹𝘁𝗮𝘁𝗶𝗼𝗻 𝗼𝗻 𝗣𝗶𝗹𝗹𝗮𝗿 𝗧𝘄𝗼 𝗱𝗼𝗺𝗲𝘀𝘁𝗶𝗰 𝗺𝗶𝗻𝗶𝗺𝘂𝗺 𝘁𝗮𝘅 𝗿𝗲𝘁𝘂𝗿𝗻   The Belgian tax authorities requested feedback from stakeholders in order to improve and clarify the Pillar Two domestic minimum tax return (DMTT).   🗓️ Stakeholders are invited to share comments and suggestions by 8 November 2024! Know more by reading the extended Tax alert.   #EY #EYBelgium #InternationalTax #CorporateTax #PillarTwo https://lnkd.in/eRXWdsX7

37

📊 Budget Day 2025 Update: Key Tax Changes You Need to Know! Today marks an important moment for businesses in the Netherlands. On this Budget Day, the government published the tax plans for 2025. One significant change to highlight is the adjustment in the interest deduction limitation rule, commonly known as the ‘earnings stripping rule.’ 🔹 What’s Changing? The permissible limit for deductible excess interest expenses will increase from 20% to 25% of the adjusted Dutch taxable profit (EBITDA for tax purposes). This adjustment offers a more lenient approach towards the financing costs businesses can deduct. 🔹 Thresholds and Conditions The earnings stripping rule will maintain its threshold where excess interest expenses up to EUR 1,000,000 are not restricted. Additionally, any excess can still be carried forward without limitation, providing flexibility for future fiscal years. 🔹 Special Focus on Real Estate A notable stipulation in the new tax plan targets real estate businesses. If a taxpayer’s adjusted property mainly consists of immovable property for at least half of the year and is made available to someone other than related entities or associated persons, these changes will particularly impact how these assets are taxed. 🔍 Implications These changes could have profound implications for financing strategies and tax liabilities, particularly for businesses heavily invested in real estate or those with significant financing costs. 💬 I’m keen to hear your thoughts on how these changes will impact our industry and your business. Let’s discuss below! #NetherlandsTax #BudgetDay2025 #Finance #BusinessTaxation

17

𝗣𝗶𝗹𝗹𝗮𝗿 𝗧𝘄𝗼 𝘂𝗽𝗱𝗮𝘁𝗲 𝗼𝗻 𝗕𝗲𝗹𝗴𝗶𝗮𝗻 𝗿𝗲𝗴𝗶𝘀𝘁𝗿𝗮𝘁𝗶𝗼𝗻 𝗽𝗿𝗼𝗰𝗲𝘀𝘀: 𝗮𝗰𝘁 𝗻𝗼𝘄 The Belgian tax authorities have issued further details on the recently introduced Pillar Two registration process. At the core is the Pillar Two Notification Form. Completion of this Form requires the collection of a substantial amount of data, a thorough understanding of the group’s (Belgian) Pillar Two position and, last but not least, access to the MyMinfin portal. On top of the administration, a very tight deadline is imposed – 30 days after the start of the First Pillar Two reporting period, extended to 45 days as of the publication date of the form for the current (or soon to start) reporting period. In-scope taxpayers are therefore urged to take immediate action! Read more about this in our recent article: https://okt.to/CbItz5 Have questions or need support? Do not hesitate to contact one of the following experts, Olivier Michiels, Paul Ampe, Jonathan Collard, Jeroen Sevens or your regular BDO contact. #PillarTwo #MyMinfin

15